tci Medicare Compliance & Reimbursement - 2009 Issue 23

HEALTHCARE REFERRALS: Avoid Holiday Gift-Giving Landmines With These 7 Steps

The recipient of your holiday gift may be your best referral source, but thanking them in writing on the card could give you a compliance nightmare before Christmas. The holidays can present one of the biggest compliance hazards to healthcare providers, thanks to gift-giving for physician referral sources. Gift-giving "is an intersection where the very rigid nature of the Stark Law collides head-on with common American business practices," warns attorney Robert Ramsey III with Buchanan Ingersoll & Rooney in Pittsburgh. "Holiday gifts are, of course, something many nonhealthcare businesses have given to their business acquaintances for years,"...

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